USA Transfer Pricing Case Law: Medtronic v. Commissioner, T.C. Memo. 2016-11

By Robert Robillard - 16 June 2016

This blogpost originally appeared on rbrt.ca. In Medtronic v. Commissioner, T.C. Memo. 2016-112, available here, the Court summarizes the main issues as follow: "(1) whether income related to intercompany licenses for the intangible property required to manufacture medical device pulse generators...

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Canada Signs the Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by-Country Reports

By Robert Robillard - 12 May 2016

This blogpost originally appeared on rbrt.ca. The OECD indicated yesterday: "As part of continuing efforts to boost transparency by multinational enterprises (MNEs), Canada, Iceland, India, Israel, New Zealand and the People’s Republic of China signed today the Multilateral Competent Authority...

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WCO: New Instrument on Transfer Pricing and Customs Valuation

By Robert Robillard - 6 May 2016

This blogpost originally appeared on rbrt.ca. The World Customs Organization explains: "The case study illustrates a scenario where Customs took into account transfer pricing information in the course of verifying the Customs value." The 4-page case study is available here. Robert...

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Canada’s Notice of Ways and Means Motion Introduces changes to FAPI and Withholding of Tax Rules

By Robert Robillard - 19 April 2016

This blogpost originally appeared on rbrt.ca. The Notice of Ways and Means Motion to implement certain provisions of the budget tabled in Parliament on March 22, 2016 and other measures and Explanatory Notes introduces changes to withholding of tax by...

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